1701 TowandaAve

. T 866

.COUNTRY PO Box 2020 www.countryfinancial.com Bloomington

. IL 61702-2020 

# Clillli;*tt

U.S. DepartmentofTransportation Docket ManagementSystem 1200NewJersey Ave. SE Washington, D.C. 20590 

### Re: Petition ofCC Services,Inc. for an Exemption Pursuant to Section 333ofthe FAA Modernization and Reform Act of2012 Dear SirorMadam: CCServices, Inc. (CC Services) hereby applies for anexemptionfrom theFederal Aviation Regulations (FARs) listed belowto enable commercial operations ofSma ll UnmannedAerial Systems (sUAS) pursuantto Section 333 ofthe FAA Modernization and Reform Act of2012 (ReformAct) and 14 C.F.R. Part 11. CC Services, Inc. seeks exemptionfrom the requirements of 14 C.F.R 

### §§ 61.113(a) & (b), 91.7(a), 91.121, 91.15l(b), 91.405(a), 91.407(a)(l),91.409(a)(l) & (a)(2), 91.417(a) & (b), and suchadditional statute orregulationasmay be necessaryto permitCCServicestocommercially oper ate sUAS for the purposeofconductingaerial imagingfor usein assessing structuresand crops for insurancefunctionsincluding: underwriting, claims assessment, roofinspection, catastrophicclaims assessment, and testingofnewimaging methods. The requested exemptionis similar to those previously granted to otherpetitioners seekingto utilize sUAS technology. Thisexemptionrequest is made based on the information inthis petition as well as the accompanying operations manuals for the sUAS to be utilized by CC Services. This petitionisorganized as follows: I. Glossary ofAbbreviations II. Description ofPetitioner III. Description ofsUASto be utilizedunderthis exemption IV. Types ofOperations V. Regulations from whichExemptionis requested VI. FederalRegister Summary VII. Additional information supporting CCServices' requestfor exemption VIII. Conclusion

CC Services Inc. Section 333 Exemption Request 1I. GLOSSARY OF ABBREVIATIONS AGL ATC CFR COA FAA FAR FMRA GCS GPS LOL MSL NAS NOT AM

PIC Section 333 SOP sUAS UAS VFR VLOS VMC vo VTOL

Above Ground Level Air Traffic Control Code of Federal Regulations Certificate of Authorization Federal Aviation Administration Federal Aviation Regulation FAA Modernization and Reform Act of2012 Ground Control Station

Global Positioning System Loss of Link Mean Sea Level National Airspace System

Notice to Airmen

Pilot in Command FAA Modernization and Refom1 Act of2012 Section 333 Standard Operating Procedure Small Unmanned Aircraft System Unmanned Aircraft System Visual Flight Rules Visual Line of Sight Visual Meteorological Conditions Visual Observer Vertical Takeoff and Landing II. Description of Petitioner CC Services is a member of the COUNTRY Financial® group of companies. COUNTRY Financial is a group of US insurance and financial services companies headquartered in Bloomington, Illinois. CC Services provides services to or on behalf of the member companies of the COUNTRY Financial group, including the affiliated property and casualty insurance companies COUNTRY Mutual Insurance Company®, COUNTRY Preferred Insurance Company®, and COUNTRY Casualty Insurance Company®. COUNTRY Financial was founded by a group of Illinois fanners in 1925 as a fire and lightning insurance company and has

grown over 90 years to encompass a wide array of insurance products including: crop, fire, home, commercial, and auto insurance. Today, COUNTRY Financial is a $3 billion insurance group comprised of eight operating companies with exclusive and independent representatives in 39 states.CC Services requests an exemption to utilize sUAS to conduct aerial imaging to improve the accuracy and speed of underwriting insurance risks and assessing insurance claims. Utilizing sUAS for aerial imaging enables risk and losses to be evaluated more rapidly and safely than current methods by eliminating the need to place employees and/or contractors at risk on ladders, on rooftops, and in light aircraft at low altitudes. Applying sUAS technologies will improve the service COUNTRY Financial can provide to its nearly I million customers nationwide. CC Services Inc. Section 333 Exemption Request 2CC Services looks forward to applying sUAS imaging across its productlines for commercial use and for internal testing ofnewtypes ofinnovative services.

Contactinfommtion for CC Services: Colin Haley Office ofGeneral Counsel 1701 TowandaAvenue Bloomington, Illinois 61701 Tel: (309) 557-3139 Fax: (309) 557-2211 Email: chaley@ilfb.org COUNTRY Financial



### III. Description ofsUAS to be Utilized Underthis Exemption CC Services will operate the included list ofsUAS to enable testing ofa wide aiTay ofimaging scenarios, andto conduct commercial imaging flights for insurance purposes. All sUAS listed by COUNTRY onthis exemptionrequest have maximum weightofless than 55 poundsincluding payload, maximum speed ofless than 87 knots (IOOmph), and will be operated at an altitude of no more than 400 feet above ground level. All operations will be conducted within Visual Line ofSight (VLOS) ofthe Pilot in Command (PIC) at all times and will beconductedper the operating manual and maintenance manual for each sUAS utilized underthe requested exemption. sUAS to beutilized underthis exemptionrequest include: I) DJI Phantom 2 2) DJI Phantom 3 

### 3) Crop Copter 4) Precisioni-Iawk Hawkeye Lancaster 

### 5) 3D Robotics Solo Manufacturer's OperatingManuals and Maintenance Manuals have been filed confidentiallyin conjunction with this exemption filing and will be utilized by the PIC for each sUAS. Dimensions and exact systems capabilities for each sUAS are included in saidmanuals. A list of the manuals provided as pat1 ofthis exemptionrequest is listed below and the documentation is provided inthe appendices: List ofAppendices containing sUAS Operating and Maintenance Manuals: A. CC Services sUAS Operating Manual 

### B. DJI Phantom 2 User Manual 

### V1.4- Serves as both Operating Manual and Maintenance Manual for DJI Phantom 2

CC Services !nc. Section 333 Exemption Request 3C. DJI Phantom 3 User Manual Vl.O- Serves as both Operating Manual and Maintenance Manual for DJI Phantom 3 D. Crop Copter User Manual v1 E. PrecisionHawk Hawkeye Lancaster sUAS Aircraft Flight Manual F. 3D Robotics Solo User Manual Should any of the sUAS manufacturers update their manuals, CC Services will substitute the revised manufacturer's documentation to ensure the most recent information is available to the PIC, VO, and other personnel involved in operating sUAS.

CC Services has also developed a set of its own SOPs and checklists to be utilized along with the Manufacturer's Operating Manuals. These checklists are included in CC Services' sUAS Operating Manual which is filed confidentially with this exemption filing as Appendix A. The Precisionl-lawk Lancaster Aircraft Flight Manual makes reference to the PrecisionHawk Flight Operations Manual in multiple places. In these cases, the CC Services UAS Operating Manual shall be used as the cross-reference for any operations conducted by CC services under the requested exemption. The sUAS operated by CC Services will be registered in accordance with 49 U.S.C. 44103, Registration of Aircraft, as well as 14 C.F.R Prut 47, Aircraft Registration, and marked in

accordance with 14 C.F.R. Part 45, Identification ru1d Registration Marking. IV. Types of Operations CC Services is requesting exemptions pursuant to Section 333 to conduct imaging ilights v-,'ith sUAS for the purposes of testing new services and providing data for assessing risk and damage for insurance purposes. Flights will be performed over private property with prior permission from the owner, operator, or occupant of the property. Testing will be perfmmed at altitudes of 400 feet AGL or less using the sUAS listed in Section III which all weigh 551b or less and will all be flown at speeds not to exceed 87kts (lOOmph). V. Regulations from which Exemption is requested, Extent of Relief Requested, and Reasons \Yhy granting the request are in the public interest and will not adversely affect safety: In accordance with 14 C.P.R.§ 11.81, CC Services provides the following infom1ation in support of its petition for exemption: A. Name And Address Of The Petitioner: The name and address of the Petitioner is: CC Services, Inc. 1701 Towanda Avenue, Bloomington, Illinois 61701 CC Services !nc. Section 333 Exemption Request 4The point ofcontact for this Petition and specific contactinformationis as follows: Colin Haley Office ofGeneral Counsel 1701 TowandaAvenue Bloomington, 1Jiinois 61701 Tel: (309) 557-3139 Fax: (309) 557-2211 Email: chaley@iltb.org 

### B. The specific sections of14 C.F.R. from which CC Services seeks 

### exemption, the extent ofsuch requested exemptions, and the reasons for each exemption are as follows: I. CC Services seeks exemption from therequirements ofSection 61.23 (a) and (c). Section 61.23 (a) and (c) entitledMedical Certificates: Requirement and Duration, state the following: (a) Operations requiring a medical certificate. Except asprovided in paragraphs (b) and (c) ofthis section, a person- (I) Musthold a first-class medical ce1tificate: (i) When exercisingthe pilot-in-commandprivileges ofan airline transportpilotcertificate; (ii) When exercising the second-in-command privileges ofan airline transport pilot ce1tificate in a flag or supplemental operation in part 121 ofthis chapterthat requires three ormore pilots; or (iii) When serving as a required pilot flightcrew memberin an operation conducted underpart 121 ofthis chapterifthe pilothas reached his orher 60thbirthday. (2) Musthold at least a second class medical certificate when exercising: (i) Second-in-command privileges ofan airline transport pilot certificateinpart 121 ofthis chapter (otherthan operations specified inparagraph (a)(l)(ii) ofthis section); or (ii) Privileges ofa commercial pilotcet1ificate; or (3) Musthold at least a third-class medical certificate- (i) When exercisingtheprivileges ofa privatepilotcertificate; (ii) When exercisingthe privileges ofa recreational pilot ce1tificate; (iii) When exercisingthe privileges ofa studentpilotcertificate; (iv) When exercisingthe privileges ofa flight instructor certificate and acting as the pilot incommand; (v) When exercisingtheprivileges ofa flight instructor certificate

CC Services Inc. Section 333 Exemption Request 5and serving as a required pilot flight crewmember; (vi) When taking a practical test in an aircraft for a recreational pilot, private pilot, commercial pilot, or airline transport pilot certificate, or for a flight insh·uctor certificate; or (vii) When performing the duties as an Examiner in an aircraft when administering a practical test or proficiency check for an airman certificate, rating, or authorization. (c) Operations requiring either a medical certiJicate or U.S. driver's license. (1) A person must hold and possess either a medical ce11ificate issued under part 67 of this chapter or a U.S. driver's license when- (i) Exercising the privileges of a student pilot certificate while seeking sport pilot privileges in a light-sport aircraft other than a

glider or balloon; (ii) Exercising the privileges of a sport pilot CCI1ificate in a lightsport aircraft other than a glider or balloon;

(iii) Exercising the privileges of a flight instructor certiJicate with a sport pilot rating while acting as pilot in command or serving as a required night crewmember of a light-sport aircraft other than a glider or balloon; or (iv) Serving as an Examiner and administering a practical test for the issuance of a sport pilot certificate in a light-sport aircraft other than a glider or balloon. (2) A person using a U.S. driver's license to meet the requirements of this paragraph must- (i) Comply with each restriction and limitation imposed by that person's U.S. driver's license and any judicial or administrative order applying to the operation of a motor vehicle; (ii) Have been found eligible for the issum1ce of at least a **third~** class ainnan medical certificate at the time of his or her most recent application (if the person has applied for a medical certificate); (iii) Not have had his or her most recently issued medical

certificate (if the person has held a medical certificate) suspended or revoked or most recent Authorization for a Special Issuance of a Medical Certificate withdrawn; and (iv) Not know or have reason to know of any medical condition that would make that person unable to operate a light-sport aircraft

in a safe manner. CC Services seeks substantially similar relief to that granted in prior 333 Exemptions to enable the PIC of an sUAS to satisfY the requirement for current medical certification for commercial operation of a sUAS with either: a ctment FAA airman medical certificate; or a valid U.S. driver's license issued by a state, the District of Columbia, Puerto Rico, a tenitory, a possession, or the Federal government. CC Services Inc. Section 333 Exemption Request 6SUAS have unique characteristics that enable the PIC to veryrapidly address any in1light emergencies involving either the PIC orequipment. These characteristics include: light weight, slow speed, short range VLOS operations, and capability oflanding safely in a wide variety oflocations. Therequested sUAS operations will offer enhanced safety when comparedwith aerial imaging conductedwith manned aircraft. 2. CC Services seeks exemption from the requirements ofSection 61.113 (a) and (b). Section 61.113, entitled Private Pilotprivileges and !imitations: Pilot in command, subsections (a) and (b) prescribethe following, inrelevant part: (a) Nopersonwhoholds a private pilot certificate may act as a pilot in command (PIC) ofan aircraft that is carryingpassengers orproperty for compensation or hire; nor maythat person, for compensation orhire, act as PIC ofan aircraft. (b) A private pilotmay, for compensationorhire, act as PIC ofan aircraft in connection with any business or employment 

### if.- (l) The flight is only incidental to that business 

### oremployment; and (2) The aircraft does not carry passengers orproperty for compensationorhire. CC Services seeks substantially similarreliefto that granted inprior 333 Exemptions, to enable the holder ofa Private Pilot certificateto operate a sUAS for commercial purposes. Thereduced risk associated with the operation ofa sUAS weighing less than 551bs and the lack ofpassengers orcrewonboard the sUAS, enable increased levels of safety whencomparedto aerial imagingwith manned aircraft. The 

### FAAhas the authority to waive pilotrequirements for commercial operations under 49U.S.C. 44701(1).

3. CC Services seeks exemptionfrom the requirements ofSection91.7 (a). Section91.7, entitled Civil aircraft airworthiness, subsection (a), states the following: (a) No person may operate a civil aircraft unless it isin an airworthy condition. Relieffrom Section 91.7(a) entitled Civil Aircraft Airworthiness, is requested to the extentrequiredto allow CC Servicesto determinethatthe sUAS listed in this exemption filing is in an airworthy condition priorto every flight byensuringthat: the sUAS is in compliancewith the manufacturer's recommended maintenanceprocedures,the sUAS undergoes a fw1ctional test flight after maintenance or alterations are performed, and that the aircraft is in a condition for safe flight. CC Services seeks the requestedreliefbecause the sUAS listed in this exemptionfiling does notrequire an airworthiness certificate in accordance with 14 C.F.R. Part 21,

CC Services Inc. Section 333 Exemption Request 7Subprut H. The combination of the sUAS being unmanned and their tight weight, will achieve an equivalent or better level of safety when compared to manned aerial imaging aircraft. 4. CC Services seeks exemption from the requirements of Section 91.119 (c). Section 91.119 (c). entitled Minimum Safe Altitudes: General, states the following in part: Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes: (a) Anywhel'e. An altitude allowing, if a power unit fails, an emergency landing without tmdue hazard to persons or property on the surface. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of I ,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft. (c) Over other than congested areas. An altitude of500 feet above the surface, except over open water or sparsely populated areas. In those

cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure. CC Services seeks substantially similar relief to that granted in prior 333 Exemptions to enable flight closer than 500 feet to nonparticipating persons, vessels, vehicles, and structures if the following criteria are satisfied: (a) BruTiers or structures are in place that sufficiently protect nonparticipating persons from the sUAS in the event of an accident; and/or (b) The ov.ner/controller of any vessels, vehicles, or structures has granted pem1ission for operating closer to those objects and the PIC assesses that

operation closer to those objects does not present an undue hazard. Due to the light weight ofsUAS and their low speed compared with manned aircraft used

for aerial imaging, CC Services can achieve an equivalent or better level of safety when operating sUAS under the conditions requested. 5. CC services seeks exemption from the requirements of Section 91.121. Section 91.121, entitled Altimeter settings, subsection (a), states the following, in patt: (a) Each person operating atl aircraft shall maintain the cruising altitude or flight level of that aircraft, as the case may be, by reference to an altimeter that is set, when operating-- CC Services Inc. Section 333 Exemption Request 8(I) Below 18,000 feet MSL, to-- (i) The currentreported altimeter setting ofa station along the route and within 100 nautical miles ofthe aircraft; (ii) Ifthere is no station withinthe area prescribed inparagraph (a)(l)(i) ofthis section, the currentreported altimeter setting ofan appropriate available station; or (iii) In the case ofan aircraft not equipped with a radio, the elevation ofthe departure airpmi or an appropriate altimeter setting available before depmture. Relieffrom Section 91.121, entitled Altimeter settings, isrequired to allowflight operations ofthe sUAS listed in this exemption filing, which utilize a combination of barometric pressure sensors, GPS equipment, and radio conununicationstelemetry to determine altitude. CC Services seeks the requested reliefbecausethe sUAS to be operated do notutilize a typical barometric altimeter on board that may be set as contemplatedby Section 91.121. Thecombination ofmethods ofdetermining altitude combined with the flight being conducted with reference to height AGL and not MSL, enable an equivalent level of safetyto conventional means ofdete1mining altitude with a barometric altimeter. 6. CC Services seeks exemptionfrom the requirements ofSection 91.151 (a) and (b). Section 9L

### 151, entitledFuel requirements for flight in VFRconditions, subsections (a) and (b), state the following: (a) Nopersonmaybegin a flight in an airplane under VFRconditions unless (considering wind and forecast weather conditions)there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed- (I) Duringthe day, to fly after that for at least 30 minutes; or (2) Atnight, to fly afterthat for at least 45 minutes. (b) No personmay begin a flight in a rotorcraft 1.mder VFRconditionsunless (considering wind and fOrecast weatherconditions) there is enough fuel to fly to the first point ofintended landing and, assuming normal cruising speed, to fly afterthat for at least 20 minutes. CC Services seeks substantially similarreliefto that granted in prior 333 Exemptionsto operate sUAS with enough available powerto conduct the intendedoperation and to operate after that for at least five minutes, orwith the reserve powerrecommendedby the manufacturer, whichever one is greater.

CC Services Inc. Section 333 Exemption Request 9Given the light weight, small size, and relatively short flight times of sUAS; and in consideration of the fact that sUAS can be landed safely in a very small landing area on very short notice; an equivalent or greater level of safety is present when operating sUAS with the proposed reserve power when compared to a manned aircraft operating with VFR minimum fuel requirements. 7. CC Services seeks exemption from the requirements of Section 9l.405(a). Section 91.405, entitled Maintenance required, subsection (a), states the following: Each

owner or operator of an**aircraft~** (a) Shall have that aircraft inspected as prescribed in subpart E of this pm1 and shall between required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter. CC Services seeks substantially similar relief to that granted in prior 333 Exemptions to follow the maintenance procedures recommended by the mmmfacturer of the sUAS, since the sUAS to be operated do not have ai1wm1hiness certificates. The light weight sUAS listed in this exemption request pose an equivalent or lower risk to the public than a**low~** flying mmmed aerial imaging aircraft. 8. CC Services seeks exemption from the requirements ofSection91.407(a)(1), Section91 .409 (a) (I) and (2), and Section 91.417 (a) and (b). Section 91.407, entitled Operation after maintenance, preventive maintenance, rebuilding, or alteration, subsection (a)(l), states the following: (a) No person may operate any aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alteration**tmless~-** (1) It has been approved fOr return to service by a person authorized under

§ 43.7 of this chapter Section 91.409, entitled Inspections, subsection (a), states the following: (a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has bad-- (1) An annual inspection in accordance with pru1 43 of this chapter and has been approved for return to service by a person authorized by § 43.7 of this chapter; or (2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. Section 91.417, entitled Maintenm1ce records, subsections (a) ru1d (b), state the following: CC Services Inc. Section 333 Exemption Request 10

### (a) Exceptfor workperformed in accordance with 

### §§ 91.411 and 91.413, each registered owner or operator shall keep the following records for theperiods specified inparagraph (b) ofthis section: (I)

### Records ofthe maintenance. preventive maintenance, and alteration and records ofthe 100-hour, annual, pl"ogressive, and otherrequired or approved inspections, as appropriate, for each aircraft (including the airframe) and eachengine, propeller, rotor, and appliance ofan aircraft. The records must include-- (i) A description (orreference to data acceptable to the Administrator) ofthe work perfonned; and (ii) The date ofcompletion ofthe workperformed; and (iii) The signature, and certificate number ofthe person approving the aircraft for return to service. (2) Records containing the following infmn1ation: (i) The total time in service ofthe airframe, each engine, each propeller, and each rotor. (ii) The current status oflife-limited parts ofeach airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul ofall items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The cunent inspection status oftheaircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained. (v) The cunent status ofapplicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. Ifthe ADor safety directive involves recurring action, the time and date when the next action is required. (vi) Copies ofthe fmms prescribedby§ 43.9(d) ofthis chapter for each majoralterationto the airframe and cunently installed engines, rotors, propellers, and appliances. (b) The owner or operator shall retain the following records for the periods prescribed:

CC Services lnc. Section 333 Exemption Request 11(1) The records specified in paragraph (a)(l) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed.

(2) The records specified in paragraph (a)(2) of this section shall be retained and transfened with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under§ 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. CC Services seeks substantially similar relief to that granted in prior 333 Exemptions to perform the sUAS manufacturer's maintenance, overhaul, replacement, inspection, and life limit requirements on the aircraft and its components without necessitating the approvals required in Section91.407 or the annual inspections specified in Part 43. The maintenance procedures for the sUAS to be operated under the requested exemption are substantially different than the maintenance for manned aircraft and are best understood by the manufacturer of the sUAS. Following the manufacturer's recommendations; when combined with the light weight, slow speed, and short range operations of the sUAS; will deliver an equivalent or increased level of safety when compared to conventional manned aircrail used for aerial imaging. 9. Certificate of Authorization- CC Services also seeks a standing COA for ongoing operations in Class G airspace for flight at or below 200 feet AGL and more than 5 miles from the nearest charted airport, as has recently been granted to other operators utilizing 333 Exemptions for

sUAS. Operations in this designated airspace pose a low risk to the general public and other rnrumed air traffic. 10. CC Services welcomes additional guidance from the FAA to prescribe other conditions it deems appropriate for safe operation. In accordance with Section 333 of the FAA Modernization and Reform Act of2012 (FMRA) and 14 C.F.R. § 21.16 entitled Special Conditions, CC Services requests that the FAA prescribe special conditions for the intended operation of the SUAS listed in this exemption filing, which contain such safety stru1dru·ds as the Adminish·ator finds appropriate to establish a level of safety equivalent to that established by 14 C.P.R. Parts §§ 61.23 (a) & (c), 6l.ll3(a) & (b), 91.7 (a). 9l.ll9 (c), 9l.l2l, 91.151 (a) & (b), 9l.405(a), 91.407(a)(l ), 91.409(a)( l) & (a)(2), and 9l.4l7(a) & (b). Such special conditions will enable CC Services's safe operation of the sUAS for the purpose of conducting aerial imaging in suppmi of insurance assessment, claims, adjustment, and R&D for new services.

CC Services Inc. Section 333 Exemption Request 12

### B. Summaryfor publication in theFederal Register, stating: TheRules FromWhich CC Services Seeks Exemption: The following summarymaybe used inthe Federal Registerto state the rules from which CC Services seeks exemption: CC Services, Inc. seeks exemption from the requirements of 14 C.F.R. Parts§§ 61.23 (a) & (c), 61.113(a) & (b), 91.7 (a), 91.119 (c), 91.121, 91.151 (a) & (b), 9l.405(a), 91.407(a)(1), 9l.409(a)(1) & (a)(2), and 91.417(a) & (b). The requested exemption will enable CC Services, Inc. to commerciallyoperate an Unmanned Aircraft System (UAS) for the purpose ofconducting aerial imaging for insurance purposes including: accelerating assessment ofcatastrophic damage, increasing efficiency ofevaluating crop insurance claims, safely evaluatingthecondition of rooftops, and performing R&D on innovative future insuranceproducts. 

### VII. Additionalinformation in support ofCC Services, request. C01is Petitionis made pursuantto the FAAModernization andReform Act of2012 (FMRA) Section 333, which directs the Secretary ofTransportationto detem1ine ifcertain UAS may operate safely intheNAS. FMRA Section 333 sets forth the requirements for evaluating whether a sUAS will create a hazard to users ofthe NAS orthe public, or otherwise pose a threat to national security; and fm1her, providesthe authority for suchUAS to operate without airworthiness certification.
As discussed in detail above, CC Services will operatethe sUAS listed in this exemptionfiling safely withinthe NAS, without creating a hazard to users ofthe NAS, orthe public; and without posing a threat to national security. 

### VIIL CONCLUSION As set fotih herein, CC Services seeks an exemptionpursuantto 14 C.F.R. § 11.61 and Section 333 ofthe FAA Modernization and Reform Act of2012 (FMRA), which will pennit safe commercial operation ofthe sUAS listed in this exemption filing, for purposes including: conducting aerial imagingfor insurance purposes including: accelerating assessment of catastrophic damage, increasing efficiency ofevaluating crop insurance claims, safely evaluating the condition ofproperty and rooftops, and performingR&D oninnovative future insurance products. By granting this Petition, the FAAAdministrator will be fulfilling the Congressional mandate of the FAA Modemization and Reforn1 Act of2012, while also advancing the interests ofthe public, by allowing CC Servicesto safely, efficiently, and economically operatethe SUAS listed in this exemption filing commercially within the NAS.

CC Services Inc. Section 333 Exemption Request 13CC Services respectfully requests that the Administrator grant this Petition for an exemption from the requirements of 14 C.P.R. Parts §§ 61.23 (a) & (c), 61.113(a) & (b), 91.7 (a), 91.119

(c), 91.121,91.151 (a) & (b), 91.405(a), 91.407(a)(1), 91.409(a)(l) & (a)(2), 91.417(a) & (b) and such additional statute or regulation as may be necessary to permit CC Services to commercially operate sUAS for the purpose of conducting aerial imaging for use in assessing structures and

crops for insurance functions including: underwriting, claims assessment, roof inspection, catastro 1ic claims assessment, and testing of new imaging methods .. Sheri Bane, Vice President Commercial Lines & Agribusiness Operations Dated: 6/25/15 CC Services Inc. Section 333 Exemption Request 14

### AppendixA- CC Senrices sUAS Operating Manual Revision 0.1 Appendices B through G: B. DJI Phantom 2 User Manual VIA- Serves as both Operating Manual and Maintenance Manual for DJI Phantom 2 C. 

### DJI Phantom 3User Manual Vl.O- 

### Serves as both Operating Manual and Maintenance Manual for DJI Phantom 3 D. Crop Copter User Manual VI E. PrecisionHawk Hawkeye Lancaster sUAS Aircraft FlightManual F. 3D Robotics Solo User Manual

CC Services Inc. Section 333 Exemption Request 15